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legal & privacy

PRIVACY POLICY, COOKIE POLICY & ACCESSIBILITY POLICY

New regulations came into force on 25 May 2018 around how organisations record, store and use your personal data. This legislation is the General Data Protection Regulation (GDPR), which is designed to give you full control over your personal data.

Shaftesbury Chinatown PLC (“Shaftesbury”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

The Company Secretary is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary at shaftesbury@shaftesbury.co.uk.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. THE DATA WE COLLECT ABOUT YOU
  2. HOW IS YOUR PERSONAL DATA COLLECTED
  3. HOW WE USE YOUR PERSONAL DATA
  4. DISCLOSURES OF YOUR PERSONAL DATA
  5. INTERNATIONAL TRANSFERS
  6. DATA SECURITY
  7. DATA RETENTION
  8. IMPORTANT INFORMATION AND WHO WE ARE
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 12.06.2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may change this policy from time to time by updating this page so please revisit and reread it periodically.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Please note that Shaftesbury does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site.

1.  THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name and last name.

Contact Data includes email address.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes feedback provided via our online contact form.

Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of an agreement  we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by  corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • enter a prize draw or promotion; or
  • give us some feedback or ask us a question via our online contact form

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.

  • Technical Data from analytics providers such as Google based outside the EU.

3. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the agreement we are about to enter into or have entered into with you.
  • Where we have your consent.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

You have the right to withdraw consent at any time by contacting contact@chinatown.co.uk.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact shaftesbury@shaftesbury.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To respond to any queries that you submit on our website (a)   Identity

(b)   Contact

Consent
To enable you to partake in a prize draw (a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a)   Identity

(b)   Contact

(c)   Technical

(a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b)   Necessary to comply with a legal obligation

To use data analytics to improve our website, services, and consumer experiences (a)   Technical

(b)   Usage

Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will get your express opt-in consent before we use or share your personal data for marketing purposes.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact contact@chinatown.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary
  • External Third Parties as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. INTERNATIONAL TRANSFERS

We do not  transfer your personal data outside the European Economic Area (EEA).

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. IMPORTANT INFORMATION AND WHO WE ARE

This privacy notice aims to give you information on how Shaftesbury collects and processes your personal data through your use of this website, including any data you may provide when you take part in a prize draw or when using our online contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Shaftesbury Chinatown PLC (registered company number 02213147) is the controller and responsible for your personal data (collectively referred to as “Shaftesbury”, “we”, “us” or “our” in this privacy notice).

CONTACT DETAILS

Our full details are:

Full name of legal entity: Shaftesbury Chinatown PLC

Name or title: Company Secretary

Email address: shaftesbury@shaftesbury.co.uk

Postal address: 22 Ganton Street, London W1F 7FD

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact contact@chinatown.co.uk for further details.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact contact@chinatown.co.uk for further details.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at shaftesbury@shaftesbury.co.uk.

Consent means processing your data where we have your consent.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Shaftesbury Group acting as joint controllers or processors and who are based in the United Kingdom.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, PR advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, PR and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

COOKIE POLICY

We are Shaftesbury Chinatown PLC (for further details about us please see our Privacy Statement). We take the privacy of visitors to this website very seriously. The purpose of this cookie policy is to inform you about the types of cookies we use on this website. This cookie policy is effective from September 2016.  We may change it from time to time by updating this page so please revisit and reread it periodically.

This site uses cookies in order to perform certain functions. On your first visit to our home page a banner appeared to make it clear that this website uses cookies and to direct you towards this cookie policy. It was explained to you on that first visit that by continuing to browse the site you would be agreeing to our use of cookies. This means that by using our website, you are deemed to be giving your consent to our use of the cookies described in this cookie policy for the purposes described. You can refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. You can also delete or block cookies at any time by altering the browser settings on your machine or other device. Further details below.

A cookie is a small piece of data sent by our server to your computer or to the other device you are using to access our website e.g. smartphone, so that information can be recalled. A cookie is stored by your web browser in a text file on your computer or other device. Each time your web browser requests content from a server that has previously interacted with your machine or other device, the cookie’s message is sent back to our server.

Cookies relating to this website are passive and just used for collecting and transferring that anonymous information. By this we mean that no cookie set while on this site will capture any personal data about you (or be used in any malicious fashion whatsoever).  Personal data is referred to in more detail in our Privacy Statement.

Two types of cookies may be used on this website; “session cookies”, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and “persistent cookies”, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).  These are referred to in more detail in the table below.

To learn more about cookies please visit http://www.allaboutcookies.org/

To learn how to adjust your browser settings so that cookies aren’t accepted or to delete or block cookies at any time please visit http://www.aboutcookies.org/default.aspx?page=1

WARNING: Many websites use cookies to deliver site functionality and you may find websites don’t work properly if you don’t accept cookies. While on this website your web browser may interact with content from different servers and therefore cookies from sources other than this site may be set on, or read from, your computer during a visit to this site. This means that this website may link through to third party websites which may also use cookies over which we have no control. We recommend that you check the relevant third party cookie policies and privacy policies for information about any cookies that may be used.

The purpose for which we use analytical/performance cookies is as follows. We use them to collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. Identifying how visitors arrive at our site and the path they take through it to help us to improve our service to you. We use third party tools to monitor and analyse traffic to, from and within our website. In addition, we use strictly necessary cookies in order for the website to function properly.

Below is a summary of the types of cookie that may be set or read while your machine or other device is used to access this site, their function, and the issuer setting this cookie:

TYPE ROLE NAME OF COOKIE(S) ISSUER(S)
SITE ANALYTICS SESSION COOKIE system to operate properly by allowing it to understand interactions in a single session. This cookie will be deleted when you close your browser. __utmc Google Analytics to opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
SITE ANALYTICS SESSION COOKIE This is a functional cookie that helps this system to operate properly by allowing it to understand interactions in a single session.  This cookie will be deleted when you close your browser. ASP.NET_SessionId or ASP The operator of this website, Shaftesbury Chinatown PLC
SITE ANALYSIS PERSISTENT COOKIE These cookies allow us to understand how often users visit our site, how long they spend there, and the pages they interact with. We do not record any information that will uniquely identify you. Instead we put together the information from a very large number of users of our website to give us an overall picture of how people visit our site. This cookie is not deleted when you close your browser and it will remain on your computer or other device unless you choose to disable it (see above for how to do that). __utma
__utmb
__utmz
Google Analytics.
To opt out of being tracked by Google Analytics across all websites visit;
http://tools.google.com/dlpage/gaoptout
STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features.  These cookies will be deleted when you close your browser. The operator of this website, Shaftesbury Chinatown PLC

FURTHER INFORMATION ON GOOGLE ANALYTICS

The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the Website analyze how you and other users use the Website. The information generated by the cookie about your use of the Website (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting this Website) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Website. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above

USE OF WEB BEACONS

Some of our website pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These web beacons do not carry any personal data about you and are only used to track the effectiveness of a particular campaign.

Because web beacons are the same as any other content request included in the recipe for a web page, you cannot opt out or refuse them. However, where they are used in conjunction with cookies they can be rendered ineffective by blocking cookies or by changing the cookie setting on your browser.  We explain how to do this at the beginning of this Cookie Policy.

ACCESSIBILITY

We aim to make this website accessible to everybody.

Changing the text size
You can enlarge or reduce the writing on this website by changing your browser’s settings as follows:

Internet Explorer
Go to View > Text size.

Chrome
Press the “Ctrl” and “+” keys at the same time to increase the font size, and the “Ctrl” and “-” keys at the same time to decrease the font size.

Firefox
Press the “Ctrl” and “+” keys at the same time to increase the font size, and the “Ctrl” and “-” keys at the same time to decrease the font size.

Alternatively, go to View > Text size.

EXTERNAL LINKS:

Please note that Shaftesbury Chinatown PLC does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site. Any external site that you visit by clicking through a link on this site that is outside the control of Shaftesbury Chinatown PLC you visit entirely at your own risk. Please read their terms and conditions. Should you find that a link which has directed you either to or from this website contains unethical material, please inform us using the ‘Contact Us’ section of our website and we will do our best to ensure that such link is removed. Should you find our website advertised and / or linked on a website you believe to be unethical or inappropriate, we would be grateful if you could inform us as soon as is reasonably practical.